Cassadaga Valley Central School District

O FFICE OF THE NEW YORK STATE COMPTROLLER DIVISION OF LOCAL GOVERNMENT & SCHOOL ACCOUNTABILITY Cassadaga Valley Central School District Financial Condition Report of Examination Period Covered: July 1, 2008 August 5, 2013 2013M-249 Thomas P. DiNapoli

Table of Contents AUTHORITY LETTER 2 Page INTRODUCTION 3 Background 3 Objective 3 Scope and Methodology 3 Comments of District Officials and Corrective Action 3 FINANCIAL CONDITION 5 General Fund Budgeting and Fund Balance 5 General Fund Reserves 7 Recommendations 10 APPENDIX A Response From District Officials 11 APPENDIX B OSC Comments on the District s Response 14 APPENDIX C Audit Methodology and Standards 15 APPENDIX D How to Obtain Additional Copies of the Report 16 APPENDIX E Local Regional Office Listing 17 DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 11

State of New York Office of the State Comptroller Division of Local Government and School Accountability December 2013 Dear School District Officials: A top priority of the Office of the State Comptroller is to help school district officials manage district resources efficiently and effectively and, by so doing, provide accountability for tax dollars spent to support district operations. The Comptroller oversees the fiscal affairs of districts statewide, as well as compliance with relevant statutes and observance of good business practices. This fiscal oversight is accomplished, in part, through our audits, which identify opportunities for improving operations and Board of Education governance. Audits also can identify strategies to reduce costs and to strengthen controls intended to safeguard district assets. Following is a report of our audit of the Cassadaga Valley Central School District, entitled Financial Condition. This audit was conducted pursuant to Article V, Section 1 of the State Constitution and the State Comptroller s authority as set forth in Article 3 of the General Municipal Law. This audit s results and recommendations are resources for district officials to use in effectively managing operations and in meeting the expectations of their constituents. If you have questions about this report, please feel free to contact the local regional office for your county, as listed at the end of this report. Respectfully submitted, Offi ce of the State Comptroller Division of Local Government and School Accountability 2 OFFICE OF THE NEW YORK STATE COMPTROLLER

Introduction Background The Cassadaga Valley Central School District is located in the Towns of Arkwright, Charlotte, Cherry Creek, Ellery, Ellicott, Ellington, Gerry, Pomfret and Stockton in Chautauqua County. The District is governed by the Board of Education (Board), which is composed of five elected members. The Board is responsible for the general management and control of the District s financial and educational affairs. The Superintendent of Schools (Superintendent) is the chief executive officer of the District and is responsible, along with other administrative staff, for the day-to-day management of the District under the direction of the Board. The Board, Superintendent and Business Administrator are responsible for the development of the District s annual budget. During our audit period, there were three schools in operation at the District: two 1 elementary schools and one middle/high school. There are 1,055 students enrolled at the District and 189 employees. General fund budgeted appropriations for the 2013-14 school year are $19,967,698, which are to be financed primarily by real property taxes and State aid. Objective The objective of our audit was to evaluate the District s financial condition and the use of fund balance and reserve funds. Our audit addressed the following related question: Does the District establish accurate and realistic budgets for the general fund and properly establish, use, and fund reserve accounts? Scope and Methodology We examined the District s financial records for the period July 1, 2008 through August 5, 2013. We conducted our audit in accordance with generally accepted government auditing standards (GAGAS). More information on such standards and the methodology used in performing this audit is included in Appendix C of this report. Comments of District Officials and Corrective Action The results of our audit and recommendations have been discussed with District officials and their comments, which appear in Appendix A, have been considered in preparing this report. Except as identified in Appendix A, District officials generally agreed with our recommendations and indicated they plan to initiate corrective 1 One of these elementary schools was closed effective June 30, 2013. DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 33

action. Appendix B includes our comments on issues raised in the District s response letter. The Board has the responsibility to initiate corrective action. Pursuant to Section 35 of the General Municipal Law, Section 2116-a (3) (c) of the Education Law and Section 170.12 of the Regulations of the Commissioner of Education, a written corrective action plan (CAP) that addresses the findings and recommendations in this report must be prepared and provided to our office within 90 days, with a copy forwarded to the Commissioner of Education. To the extent practicable, implementation of the CAP must begin by the end of the next fiscal year. For more information on preparing and filing your CAP, please refer to our brochure, Responding to an OSC Audit Report, which you received with the draft audit report. The Board should make the CAP available for public review in the District Clerk s office. 4 OFFICE OF THE NEW YORK STATE COMPTROLLER

Financial Condition General Fund Budgeting and Fund Balance A school district s financial condition is a factor in determining its ability to provide educational services to students. The responsibility for accurate and effective financial planning rests with the Board, the Superintendent and the Business Administrator. One of the most important tools for managing a district s financial condition is the budget process. District officials must ensure that budgets are prepared, adopted and modified in a prudent manner, accurately depict the District s financial activity and use available resources to benefit District taxpayers. Prudent fiscal management also includes maintaining sufficient balances in reserves that are needed to address long-term obligations or planned future expenditures. In doing so, District officials should adopt a policy governing the use of reserve funds and ensure that residents are fully informed of all reserve funding activity. District officials consistently overestimated expenditures in the general fund by a total of $6.3 million over the five-year period ending June 30, 2013. Therefore, the District did not need to use the $5.8 million of fund balance that the Board appropriated as a funding source in the general fund budgets for the same five-year period. Instead, the District has experienced operating surpluses in the general fund for four of the last five years, totaling $1,100,434, leading to unexpended surplus fund balance 2 exceeding the statutory limit of 4 percent of the ensuing year s operations for the last two fiscal years. Also, District officials could not demonstrate a planned need for more than $876,000 in reserves. The Board is responsible for preparing and presenting the District s budget to the public for vote. In preparing the budget, the Board is responsible for estimating expenditures, as well as what the District will receive in revenue (e.g., State aid), how much fund balance will be available at fiscal year-end (some or all of which may be used to fund the ensuing year s appropriations) and, to balance the budget, what the expected tax levy will be. Accurate estimates help ensure that the levy of real property taxes is not greater than necessary. 2 The Governmental Accounting Standards Board (GASB) issued Statement 54, which replaces the fund balance classifications of reserved and unreserved with new classifications: nonspendable, restricted, committed, assigned and unassigned. The requirements of Statement 54 are effective for fiscal years ending June 30, 2011 and beyond. To ease comparability between fiscal years ending before and after the implementation of Statement 54, we will use the term unexpended surplus funds to refer to that portion of fund balance that was classified as unreserved, unappropriated (prior to Statement 54), and is now classified as unrestricted, less any amounts appropriated for the ensuing year s budget (after Statement 54). DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 55

The estimation of fund balance is an integral part of the budget process. Fund balance represents resources remaining from prior fiscal years that can be used to lower property taxes for the ensuing fiscal year. A district may retain a portion of fund balance, referred to as unexpended surplus funds, within the 4 percent limit. Districts may also establish reserves to restrict a portion of fund balance for a specific purpose, also in compliance with statutory directives. It is the Board s responsibility to continually monitor the need for all established reserves to ensure that the best interests of the taxpayers are being met. We compared the District s budgeted revenues and expenditures with actual results of operations for fiscal years 2008-09 through 2012-13 and found that the District has overestimated expenditures by a total of approximately $6.3 million, as indicated in Table 1. District officials consistently overestimated certain expenditure groups, including employee benefits ($1.9 million), programs for handicapped children ($1.05 million), transportation ($990,000), utilities ($620,000), and debt service ($530,000). Table 1: General Fund Expenditures Fiscal Year Budgeted Expenditures Actual Expenditures Difference 2008-09 $19,514,000 $18,076,024 ($1,437,976) 2009-10 $19,910,000 $18,827,459 ($1,082,541) 2010-11 $19,910,001 $18,792,210 ($1,117,791) 2011-12 $19,910,000 $18,430,637 ($1,479,363) 2012-13 $19,998,000 $18,766,978 ($1,231,022) Total ($6,348,693) The Board appropriated fund balance each year to reduce the tax levy, which should have resulted in planned operating deficits each year. While the District incurred an operating deficit of $228,776 in fiscal year 2011-12, the District incurred operating surpluses in the other four years. Over the five-year period ending June 30, 2013, actual revenues exceeded actual expenditures by $871,658, as indicated in Table 2. 6 OFFICE OF THE NEW YORK STATE COMPTROLLER

Table 2: General Fund Results of Operations 2008-09 2009-10 2010-11 2011-12 2012-13 Total Beginning Fund Balance $2,894,330 $3,425,051 $3,667,829 $3,931,733 $3,702,957 Actual Revenues $18,606,748 $19,255,235 $18,871,117 $18,201,861 $18,830,005 $93,764,966 Actual Expenditures $18,076,024 $18,827,459 $18,792,210 $18,430,637 $18,766,978 $92,893,308 Operating Surplus/ (Deficit) $530,724 $427,776 $78,907 ($228,776) $63,027 $871,658 Ending Fund Balance $3,425,054 $3,852,827 $3,746,736 $3,702,957 $3,765,984 Prior Period Adjustment/ Rounding ($3) ($184,998) $184,997 $0 ($2) Adjusted Ending Fund Balance $3,425,051 $3,667,829 $3,931,733 $3,702,957 $3,765,982 Less: Appropriated Unexpended Surplus Fund Balance at June 30 $533,000 $957,608 $1,357,508 a $957,608 $591,305 Less: Restricted Fund Balance $2,156,423 $2,167,622 $2,277,669 $1,680,544 $1,683,933 Less: Encumbrances $6,248 Unexpended Surplus Fund Balance at June 30 $735,628 $542,599 $296,556 $1,058,557 $1,490,744 a Appropriated fund balance per adopted budget dated May 17, 2011. District reported $957,608 in its fi nancial statements. The District s practice of consistently appropriating fund balance not needed to finance operations is, in effect, a reservation of fund balance that is neither regulated by statute nor subject to the statutory limit for unexpended surplus fund balance. During this same period, although revenues exceeded expenditures, the Board increased the tax levy each year, from $4.42 million in 2008-09 to $5 million in 2012-13, an increase of 13 percent. The District s adopted budget for 2013-14 includes another tax increase of 2 percent, to $5.1 million. District officials unrealistic budget estimates and practices have caused the District s unexpended surplus fund balance to be 5 percent of the ensuing year s operations at June 30, 2012 and 7 percent at June 30, 2013, which exceeded the 4 percent statutory limit. The District s 2011-12 independent audit report contained a finding related to the unexpended surplus fund balance exceeding the statutory limit. Budgeting practices which produce operating surpluses and maintain fund balances that exceed the amount allowed by law result in real property tax levies that are greater than necessary to fund operations. General Fund Reserves Reserve funds may be established by Board action, pursuant to various laws, and are used to provide financing for specific purposes. The statutes under which the reserves are established determine how the reserves may be funded, expended or discontinued. Generally, school districts are not limited to how much money can be held DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 77

8 OFFICE OF THE NEW YORK STATE COMPTROLLER in reserves. However, it is important that school districts maintain reserve balances that are reasonable. Funding reserves at greater than reasonable levels results in real property tax levies that are higher than necessary, because the money held in the reserves would otherwise be subject to the statutory limit for fund balance. A governing board that establishes and funds reserves on a regular basis should adopt a written policy that communicates clearly its rationale for establishing reserve funds, objectives for each reserve established, optimal or targeted funding levels and conditions under which the funds assets will be used or replenished. Reserve fund transactions should be transparent to the public. Reserves are typically funded from amounts raised through the annual budget process, transfers from unexpended balances of existing appropriations, and surplus moneys. Ideally, amounts to be placed in reserves should be included in the annual budget; reserves should not routinely be funded at year-end from excess fund balance. The District s three reserves totaled $1.7 million as of June 30, 2013, a decrease of 27 percent from June 30, 2009 due mainly to the transfer of approximately $600,000 of excess funding from the employee benefit accrued liability reserve (EBALR) back to the general fund in August 2011. This transfer contributed to the general fund exceeding its statutory limit for fund balance at June 30, 2012. Currently, the District s reserve balances are $876,000 greater than the District s documented planned needs. By maintaining excessive and/ or unnecessary reserves, the Board may have missed opportunities to lower the property tax burden and withheld significant funds from being used to meet District needs. Unemployment Insurance Reserve General Municipal Law (GML) authorizes the Board to create an unemployment insurance reserve fund to reimburse the State Unemployment Insurance Fund (SUIF) for payments made to claimants where the school district has elected to use the benefit reimbursement method based on actual unemployment claims. If, at the end of any fiscal year, the moneys in the reserve exceed amounts required to be paid into the SUIF, plus any additional amounts required to pay all pending claims, the Board may, within 60 days of the close of the fiscal year, elect to transfer excess amounts to certain other reserve funds or apply this excess to the budget appropriations of the next succeeding fiscal year. As of June 30, 2013, the reserve had a reported balance of $242,333. While the District incurred average unemployment insurance costs of approximately $17,000 since 2008-09, these expenditures were not charged to this reserve. The District paid these costs from general

fund appropriations, which were funded through the annual tax levy, rather than using the funds reserved for this purpose. If unemployment costs continue to average about $17,000 per year, 3 this reserve at its currently funded level would last for nearly 14 years, assuming that taxes were no longer levied to fund this cost. We question the reasonableness of reserving this level of funding for this purpose. Retirement Contribution Reserve GML authorizes the Board to create a retirement contribution reserve to finance retirement contributions payable to the New York State and Local Employees Retirement System (ERS). The District cannot include the cost of financing contributions for employees covered by the New York State Teachers Retirement System. A portion of the funds in this reserve may be transferred to certain other reserves in accordance with statutory requirements. As of June 30, 2013, the reserve had a reported balance of $455,367. The District has incurred increasing contribution costs for ERS over the last five years. However, the District did not charge any part of its ERS expenditures, totaling $315,137 in the 2012-13 fiscal year, to this reserve. Instead, the District paid these costs from general fund appropriations, funding them through the annual tax levy. Given the absence of a formalized plan detailing the need and expected use of these funds, we question the need for this reserve. EBALR GML requires that the EBALR be used only for the cash payment of accrued and unused sick, vacation and certain other accrued but unused leave time earned by employees, as well as expenses related to the administration of the reserve. To be funded from this reserve, the accrued and non-liquidated benefits must be due and payable to the employee upon separation from service. The Board is responsible for ensuring that the balance in this reserve is appropriate, and the basis of funding is adequately supported by the monetary value of accrued leave time due as cash payments to employees upon separation from service. As of June 30, 2013, the District had a balance of $986,234 in the reserve. The District provided supporting documentation for $632,582 in long-term compensated absences. However, the District s documentation excluded potential liabilities of $175,778. As such, this reserve is overfunded by a total of $177,874. By maintaining excessive and/or unnecessary reserves combined with ongoing budgeting practices that generate repeated surpluses the Board and District officials have withheld significant funds from 3 Unemployment costs totaled $9,933 for fiscal year 2012-13. DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 99

productive use, levied unnecessarily high taxes and compromised the transparency of District finances to taxpayers. Recommendations 1. The Board and District officials should develop realistic expenditure and fund balance estimates for the annual general fund budget. 2. District officials should develop comprehensive policies related to the establishment and use of reserve funds. These policies should outline the optimal or targeted funding levels and the conditions under which the funds will be used or replenished. 3. The Board and District officials should review all reserves and determine if the amounts reserved are necessary, reasonable and in compliance with statutory requirements. 4. District officials should develop a plan for the use of the surplus balances in the reserve funds identified in this report in a manner that benefits District taxpayers. Such uses could include, but are not limited to: Increasing other necessary reserves, Paying off debt, Financing one-time expenses, and Reducing District property taxes. 10 OFFICE OF THE NEW YORK STATE COMPTROLLER

APPENDIX A RESPONSE FROM DISTRICT OFFICIALS The District officials response to this audit can be found on the following pages. DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 111

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See Note 1 Page 14 See Note 2 Page 14 See Note 3 Page 14 DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 1313

APPENDIX B OSC COMMENTS ON THE DISTRICT S RESPONSE Note 1 The purpose of Table 1 is to show the major cause of the annual operating surpluses consistent overestimation of expenditures. The District budgeted each year to use a portion of the cumulative surplus towards the ensuing year s budget which, if used, should have resulted in an operating deficit and subsequent reduction of the District s surplus. However, because expenditures were significantly overestimated, surplus was only actually used in one of the years we reviewed, and, even then, the amount used was much less than budgeted. The District should develop estimates for expenditures and utilize unexpended surplus funds in a manner that best serves the District and its taxpayers when developing the annual budget. Note 2 As indicated in the OSC publication Local Government Management Guide Reserve Funds, dated January 2010, The practice of planning ahead and systematically saving for capital acquisitions and other contingencies is considered prudent management. An important concept to remember is that a reserve fund should be established with a clear intent or plan in mind regarding the future purpose, use and, when appropriate, replenishment of funds from the reserve. Reserve funds should not merely be a parking lot for excess cash or fund balance. Our audit found that the District does not have a written plan in place with a clear intent or plan regarding the purpose, use and replenishment of reserve funds. Note 3 Fiscal prudence dictates that the balance of the EBALR should not exceed the long-term portion of the liability for compensated absences. According to the GASB statement 16, the compensated absences liability generally should be calculated based on the pay or salary rates in effect as of the balance sheet date. 14 OFFICE OF THE NEW YORK STATE COMPTROLLER

APPENDIX C AUDIT METHODOLOGY AND STANDARDS Our overall goal was to assess the adequacy of the internal controls put in place by officials to safeguard District assets. To accomplish this, we performed an initial assessment of the internal controls so that we could design our audit to focus on those areas most at risk. Our initial assessment included evaluations of the following areas: financial condition, cash receipts and disbursements, payroll, cafeteria operations, transportation and information technology. During our initial assessment, we interviewed appropriate District officials, performed limited tests of transactions, and reviewed pertinent documents such as District policies, Board minutes and financial records and reports. After reviewing the information gathered during our initial assessment, we determined where weaknesses existed and evaluated those weaknesses for the risk of potential fraud, theft and/or professional misconduct. We then decided upon the reported objective and scope by selecting for audit those areas most at risk. We selected financial condition for further audit testing. We examined District records and reports for the period July 1, 2008 to August 5, 2013. To accomplish our objective, we performed the following procedures: We interviewed District officials to gain an understanding of the processes and procedures in place over the District s financial management. We compared ST-3 reported amounts to the District s externally audited financial statements and bank statements to verify reliability. We reviewed ST-3 reports for the audit period to document fund balance, reserve funds, revenues and expenditures. We reviewed the tax warrants, receipts and levy increases. We compared fund balance to the ensuing year s appropriations to determine if the District was within the statutory limit. We reviewed Board minutes and resolutions, as well as other documentation, to determine that reserve funds were created, funded and expended properly. We performed budget-to-actual comparisons of revenues and expenditures to determine if there were operating surpluses or deficits and to determine if the budgets were realistic and supported. We conducted this performance audit in accordance with generally accepted government auditing standards (GAGAS). Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objective. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objective. DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 1515

APPENDIX D HOW TO OBTAIN ADDITIONAL COPIES OF THE REPORT To obtain copies of this report, write or visit our web page: Office of the State Comptroller Public Information Office 110 State Street, 15th Floor Albany, New York 12236 (518) 474-4015 http://www.osc.state.ny.us/localgov/ 16 OFFICE OF THE NEW YORK STATE COMPTROLLER

APPENDIX E OFFICE OF THE STATE COMPTROLLER DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY Andrew A. SanFilippo, Executive Deputy Comptroller Gabriel F. Deyo, Deputy Comptroller Nathaalie N. Carey, Assistant Comptroller LOCAL REGIONAL OFFICE LISTING BINGHAMTON REGIONAL OFFICE H. Todd Eames, Chief Examiner Office of the State Comptroller State Office Building - Suite 1702 44 Hawley Street Binghamton, New York 13901-4417 (607) 721-8306 Fax (607) 721-8313 Email: Muni-Binghamton@osc.state.ny.us Serving: Broome, Chenango, Cortland, Delaware, Otsego, Schoharie, Sullivan, Tioga, Tompkins Counties BUFFALO REGIONAL OFFICE Robert Meller, Chief Examiner Office of the State Comptroller 295 Main Street, Suite 1032 Buffalo, New York 14203-2510 (716) 847-3647 Fax (716) 847-3643 Email: Muni-Buffalo@osc.state.ny.us Serving: Allegany, Cattaraugus, Chautauqua, Erie, Genesee, Niagara, Orleans, Wyoming Counties NEWBURGH REGIONAL OFFICE Tenneh Blamah, Chief Examiner Office of the State Comptroller 33 Airport Center Drive, Suite 103 New Windsor, New York 12553-4725 (845) 567-0858 Fax (845) 567-0080 Email: Muni-Newburgh@osc.state.ny.us Serving: Columbia, Dutchess, Greene, Orange, Putnam, Rockland, Ulster, Westchester Counties ROCHESTER REGIONAL OFFICE Edward V. Grant, Jr., Chief Examiner Office of the State Comptroller The Powers Building 16 West Main Street Suite 522 Rochester, New York 14614-1608 (585) 454-2460 Fax (585) 454-3545 Email: Muni-Rochester@osc.state.ny.us Serving: Cayuga, Chemung, Livingston, Monroe, Ontario, Schuyler, Seneca, Steuben, Wayne, Yates Counties GLENS FALLS REGIONAL OFFICE Jeffrey P. Leonard, Chief Examiner Office of the State Comptroller One Broad Street Plaza Glens Falls, New York 12801-4396 (518) 793-0057 Fax (518) 793-5797 Email: Muni-GlensFalls@osc.state.ny.us Serving: Albany, Clinton, Essex, Franklin, Fulton, Hamilton, Montgomery, Rensselaer, Saratoga, Schenectady, Warren, Washington Counties SYRACUSE REGIONAL OFFICE Rebecca Wilcox, Chief Examiner Office of the State Comptroller State Office Building, Room 409 333 E. Washington Street Syracuse, New York 13202-1428 (315) 428-4192 Fax (315) 426-2119 Email: Muni-Syracuse@osc.state.ny.us Serving: Herkimer, Jefferson, Lewis, Madison, Oneida, Onondaga, Oswego, St. Lawrence Counties HAUPPAUGE REGIONAL OFFICE Ira McCracken, Chief Examiner Office of the State Comptroller NYS Office Building, Room 3A10 250 Veterans Memorial Highway Hauppauge, New York 11788-5533 (631) 952-6534 Fax (631) 952-6530 Email: Muni-Hauppauge@osc.state.ny.us STATEWIDE AUDITS Ann C. Singer, Chief Examiner State Office Building - Suite 1702 44 Hawley Street Binghamton, New York 13901-4417 (607) 721-8306 Fax (607) 721-8313 Serving: Nassau and Suffolk Counties DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 1717